3rd

STATE OF MICHIGAN
JUDICIAL CIRCUIT COURT
COUNTY OF WAYNE

BILL SCHUETTE, Attorney General

of the State of Michigan,
Plaintiff,
v

Case No. 16-_____________-AW

Honorable ___________________

SUMMIT OF DETROIT, P.C.,

SUMMIT WOMENS CENTER OF DETROIT, INC.
DAVID LIPTON, in his capacity as Officer,
director and shareholder of Summit of Detroit, P.C. and
Summit Womens Center of Detroit, Inc., and
ANISE BURRELL, Administrator of Summit of Detroit, P.C.
and Summit Womens Center of Detroit, Inc.
Defendants.
William R. Bloomfield (P68515)
Mark A. Gabrielse (P75163)
Assistant Attorneys General
Attorneys for Plaintiff
Michigan Department of Attorney General
Corporate Oversight Division
P.O. Box 30755
Lansing, MI 48909
Telephone: (517) 373-1160
There is no other pending or resolved civil action arising out of the
transaction or occurrence alleged in this Complaint.

VERIFIED COMPLAINT FOR QUO WARRANTO

TO DISSOLVE SUMMIT OF DETROIT, P.C.,
AND FOR INJUNCTIVE AND OTHER RELIEF

Plaintiff Bill Schuette, Attorney General of the State of Michigan, and

William R. Bloomfield and Mark A. Gabrielse, Assistant Attorneys General,
representing the People of the State of Michigan, bring this Complaint for quo
warranto against Defendants and requesting the dissolution of Summit of Detroit,
P.C., and injunctive relief and fines against all Defendants. In support of the
Complaint, the Attorney General alleges:
THE PARTIES
1.

Plaintiff is the Attorney General of the State of Michigan, appearing on

behalf of the People of the State of Michigan under his statutory and common law
authority to bring this quo warranto Complaint. MCR 3.306.
2.

Defendant Summit Womens Center of Detroit, Inc. (Summit Inc.) is

a foreign profit corporation with a registered office address of 601 Abbot Road, East
Lansing, MI 48823. Its registered agent is CSC-Lawyers Incorporating Service.
Summit Inc. obtained its certificate of authority to transact business in Michigan on
April 13, 2007 and was assigned an identification number of 60052T.
3.

Defendant Summit of Detroit, P.C. (Summit P.C.) is a domestic

professional corporation with a registered office address of 601 Abbot Road, East
Lansing, MI 48823. Its registered agent is CSC-Lawyers Incorporating Service.
Summit P.C. was incorporated on May 4, 2011 and was assigned an identification
number of 03622L. Summit P.C. has also registered the following assumed names:
Summit Womens Center of Michigan; Summit Women Center; Summit Medical
Center; and Summit Medical Center of Michigan.

4.

Defendant David Lipton is the president, secretary, treasurer, and

director for both Summit Inc. and Summit P.C. Defendant Lipton is also the sole
shareholder of Summit P.C.
5.

Defendant Anise Burrell signed the 2013 Summit P.C. annual report to

LARA as its administrator. Burrell is also listed as the contact on Summit P.C.s
four Certificate of Assumed Name filings filed with LARA on November 22, 2013.
And Defendant Burrell is listed as the administrator for Summit Inc. on the June 4,
2015 state licensure survey conducted by the Department of Licensing and
Regulatory Affairs.

STANDING, JURISDICTION, AND VENUE

6.

Standing, jurisdiction, and venue are authorized by the following

statutes and court rules.

7.

Section 821 of Michigans Business Corporation Act states:

(1) The attorney general may bring an action in the circuit court of
the county in which the principal place of business or registered
office of the corporation is located for dissolution of a corporation
upon the ground that the corporation has committed any of the
following acts:
(a) Procured its organization through fraud.
(b) Repeatedly and willfully exceeded the authority conferred
upon it by law.
(c) Repeatedly and willfully conducted its business in an
unlawful manner.
(2) The enumeration in this section of grounds for dissolution does
not exclude any other statutory or common law action by the
attorney general for dissolution of a corporation or revocation or
forfeiture of its corporate franchises. [MCL 450.1821.]

8.

Section 286 of the Business Corporation Act specifically authorizes the

Attorney General to dissolve a professional corporation whose officer or shareholder

is legally disqualified from providing professional services:
If an officer, shareholder, agent, or employee of a professional
corporation becomes legally disqualified to provide the professional
services provided by the corporation, or accepts employment that
under existing law restricts or limits his or her authority to continue
providing those professional services, he or she shall sever within a
reasonable period all employment with and financial interests in the
professional corporation. A professional corporation's failure to
require compliance with this section is grounds for the
forfeiture of its articles of incorporation and its dissolution. If a
professional corporation's failure to comply with this section is brought
to the attention of the administrator, he or she shall notify the
attorney general of the failure and the attorney general may take
appropriate action to dissolve the professional corporation.
[MCL 450.1286 (Emphasis added).]
9.

Section 3601 of the Revised Judicature Act empowers this Court to

grant injunctive relief against a corporate or individual defendant in response to the

Attorney Generals complaint, stating:
(1) Upon complaint being filed by the attorney general, the circuit
court may enjoin any corporation from assuming or exercising any
franchise, liberty, or privilege or transacting any business not
authorized by the corporation's charter. The court may in the same
manner restrain any individuals from exercising any corporate
rights, privileges, or franchises which have not been granted to
them by the laws of this state.
(2) The court may issue the injunction before the answer, upon
satisfactory proof that the defendants have usurped, exercised or
claimed any franchise, privilege, liberty, or corporate right not
granted to them; and after the answer the injunction may be
continued until final judgment is had. [MCL 600.3601.]
See also MCL 600.3605 for jurisdiction of the circuit courts over corporate
matters.

10.

Section 4501 of the Revised Judicature Act requires the Attorney

General to bring the present quo warranto action, since Defendants are clearly
violating the authority granted to a professional corporation. Section 4501 states:
The attorney general shall bring an action for quo warranto when the
facts clearly warrant the bringing of that action. If the attorney
general receives information from a private party and refuses to act,
the private party may bring the action upon leave of court. [MCL
600.4501 (Emphasis added).]
11.

The Court Rules also support both the Attorney Generals authority to

bring the present action for quo warranto and venue in the circuit court. MCR 3.306
states:
(A) Jurisdiction.
(1) An action for quo warranto against a person who
usurps, intrudes into, or unlawfully holds or exercises a
state office, or against a state officer who does or suffers
an act that by law works a forfeiture of the office, must be
brought in the Court of Appeals.
(2) All other actions for quo warranto must be brought in
the circuit court.
(B) Parties.
(1) Actions by Attorney General. An action for quo
warranto is to be brought by the Attorney General when
the action is against:
(d) a corporation that is in violation of a provision of the
act or acts creating, offering, or renewing the corporation;
(e) a corporation that has violated the provisions of a law
under which the corporation forfeits its charter by misuse;
***
(D) Venue. The general venue statutes and rules apply to
actions for quo warranto, unless a specific statute or rule
contains a special venue provision applicable to an action
for quo warranto.
12.

Venue is proper in Wayne County under Section 1621 of the Revised

Judicature Act, which states: The county in which a defendant resides, has a place
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of business, or conducts business, or in which the registered office of a defendant

corporation is located, is a proper county in which to commence and try an action.
MCL 600.1621. Defendants conduct business at Summit Womens Center, which is
located at 15801 W. McNichols Road, Detroit, Michigan in Wayne County.
COMMON ALLEGATIONS
First Complaints
13.

In late 2013, the Attorney General received two complaints regarding a

possible violation of Michigans laws regarding professional corporations, which

require corporations providing services in a learned profession to incorporate as a
professional corporation owned by a licensed person in that learned profession. The
complaints alleged that Summit Inc. was providing medical services performed by
physicians, but was not owned by a physician.
14.

Sections 281 through 289 of the Business Corporations Act address

professional corporations. Section 281 states: A corporation must incorporate as a

professional corporation under this chapter if it is incorporated to provide 1 or more
services in a learned profession, whether or not it is providing other professional
services. MCL 450.1281. Section 283(2) states: Each shareholder of a professional
corporation must be a licensed person in 1 or more of the professional services
provided by the professional corporation. MCL 450.1283(2).
15.

At the time of the complaints, a review of Summit Inc.s corporate

filings with LARA showed that Summit Inc. was a foreign profit corporation
incorporated in the state of Georgia and operating in Michigan under a certificate of
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authority since 2007. Defendant David Lipton of Fairfield, Connecticut was listed as
Summit Inc.s sole officer and director. Summit Inc.s stated corporate purpose was
management services. Exhibit A, Summit Inc.s filings with LARA.
16.

After reviewing the complaints, the corporate filings of Summit Inc.,

and the website for Summit Medical Centers, in February 2014 the Attorney
General requested information from Summit Inc. related to its corporate form and
business activities. Exhibit B, February 6, 2014 Letter. Summit Inc., through
counsel, responded and explained that Summit Inc. provided management and
administrative services to Summit P.C., a professional corporation owned by Alex
Pickens, Jr., MD. Exhibit C, February 24, 2015 Response Letter with agreements
and Summit P.C. Bylaws. The response also explained that Summit P.C. employed
the physicians who provided medical services at the clinic and that Pickens both
provided medical services and served as the clinics medical director. The response
included various supporting documentation, including the articles of incorporation
for Summit P.C., the Management and Administrative Services Agreement
(Agreement) between Summit Inc. and Summit P.C., and the professional service
agreements of those doctors employed by Summit P.C. The Agreement was entered
into on January 1, 2012 and remains valid through January 1, 2017.
17.

Because the documentation showed that medical services were being

provided through a professional corporation owned by a licensed physician in

compliance with Michigan law, the Attorney General closed the complaint. To
clarify against future confusion, the Attorney General asked Summit Inc. to modify

its website to clarify its relationship with Summit P.C.. Summit Inc. agreed and
updated its website to state:
All medical services are provided by the highly respected doctors and
caring professional staff of Summit of Detroit, P.C. Summit Womens
Center of Detroit, Inc., an experienced medical management company,
provides administrative services at the clinic and can assist patients
with payment options. [Exhibit D, screen shot from
www.summitcenters.com/detroit-abortion-clinic, last visited April 7,
2016.]
As of the date of this Complaints filing, Summit Inc.s website still includes
the above language.

Second Complaints
18.

In June 2015, about a year after the Attorney General closed the first

complaints, a new complaint was submitted to the Attorney General. This

complaint alleged that Summit P.C.s ownership had changed and that it was no
longer owned by a licensed physician; hence Summit P.C. was providing medical
services in violation of Michigans laws for professional corporations.
19.

A second complaint with similar allegations against Summit P.C. was

submitted to the Attorney General in December 2015.

20.

The Attorney Generals review of Summit P.C.s corporate filings with

LARA has confirmed the complaints. Exhibit E, Summit P.C.s corporate filings
with LARA. From its incorporation in 2011 through its annual report of 2014,
Summit P.C.s sole officer and director was Alex Pickens, Jr., MD, a licensed
physician; but on May 11, 2015, Defendant David Lipton filed the 2015 annual

report with LARA certifying that he was Summit P.C.s president, secretary,
treasurer, director, and sole shareholder. Id. The form Summit P.C. filed with
LARA states: The corporation certifies that each shareholder is a licensed person
in 1 or more of the professional services provided by the professional corporation
and the corporation meets the other requirements of chapter 2A. The names and
addresses of all shareholders are: David Lipton, 61 Unquowa Road, Fairfield CT
06824. Id.
21.

A search of LARAs licensing records confirms that David Lipton of

Fairfield, Connecticut is not a licensed physician in Michigan. Exhibit F, Results

from LARA Verify a License or Registration.
22.

Additionally, the complaint alleged that Alex Pickens, Jr., MD had

filed for bankruptcy. A review of Pickenss bankruptcy petitionsigned under

penalty of perjury on November 29, 2013shows that Pickens failed to list Summit
P.C. as an asset or entity in which Pickens holds an asset. The petition required
Pickens to disclose all businesses in which [he] was an officer, director, partner, or
managing executive . . . within six years of commencing the bankruptcy. Exhibit
G, Bankruptcy Petition, pages 28 and 31 of 39. Pickens disclosed three businesses:
one professional corporation, one business corporation, and one nonprofit
corporation. But he did not list Summit P.C. Only one month before this
certification to the bankruptcy court, in October 2013, Pickens signed four
certificates of assumed name filed with LARA on behalf of Summit P.C. Exhibit E.
Pickenss failure to disclose his ownership of Summit P.C. to the bankruptcy court,

and the subsequent filing of ownership by David Lipton, suggests that Alex Pickens,
Jr., MD may never have been the true owner of Summit P.C. and that Summit P.C.
was organized through fraud and repeatedly and willfully exceeded its authority.

COUNT I
QUO WARRANTO DISSOLUTION OF SUMMIT OF DETROIT,
P.C. AND OTHER RELIEF
23.

Plaintiff incorporates by reference the preceding paragraphs.

24.

A corporation providing services in a learned profession must

incorporate as a professional corporation. MCL 450.1281(1). A corporation that is

incorporated to provide a professional service not in a learned profession may
incorporate as a professional corporation, but is not required to do so. Id.
25.

The practice of medicine is one of the traditional learned professions,

and medical services may not be offered and/or provided to the public by a person or
entity organized as a domestic profit corporation or limited liability company. OAG,
1979-1980, No. 5676, p 700 (April 8, 1980); OAG, 1989-1990, No. 6592, p 166 (July
10, 1989).
26.

Professional service is defined as a type of personal service to the

public that requires that the provider obtain a license or other legal authorization
as a condition precedent to providing that service. MCL 450.1282(b).
27.

When forming a professional corporation, MCL 450.1283 requires the

following:

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(1) Except as provided in this section, 1 or more licensed persons

may form a professional corporation under this chapter.
(2) Each shareholder of a professional corporation must be a
licensed person in 1 or more of the professional services provided
by the professional corporation.
(3) Except as provided in this section or otherwise prohibited,
the articles of incorporation of a professional corporation shall
state that the professional corporation is formed to provide 1 or
more professional services and shall state the specific
professional service or services the professional corporation is
formed to provide.
(4) The name of a professional corporation shall contain the
words professional corporation or the abbreviation P.C. with
or without periods or other punctuation.
28.

A professional corporation shall not provide professional services in

this state except through its officers, employees, and agents who are duly licensed
or otherwise legally authorized to provide the professional services in this state.
MCL 450.1285(1).
29.

A professional corporation is not permitted to engage in any business

other than providing the professional service . . . for which it was specifically
incorporated. MCL 450.1287(1).
30.

Once a professional corporation is formed, shares of that professional

corporation shall not be sold or transferred except to a person who is eligible to be a

shareholder of the professional corporation. MCL 450.1288(2).

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31.

MCL 450.1286 specifically authorizes the Attorney General to

dissolve a professional corporation whose officer or shareholder is legally

disqualified from providing professional services:
If an officer, shareholder, agent, or employee of a professional corporation
becomes legally disqualified to provide the professional services provided by
the corporation, or accepts employment that under existing law restricts or
limits his or her authority to continue providing those professional services,
he or she shall sever within a reasonable period all employment with and
financial interests in the professional corporation. A professional
corporation's failure to require compliance with this section is
grounds for the forfeiture of its articles of incorporation and its
dissolution. If a professional corporation's failure to comply with this section
is brought to the attention of the administrator, he or she shall notify the
attorney general of the failure and the attorney general may take
appropriate action to dissolve the professional corporation. [MCL
450.1286 (Emphasis added).]
32.

On May 4, 2011, Summit P.C. filed its Articles of Incorporation to be a

domestic professional corporation under the Business Corporations Act. Summit

P.C.s Articles of Incorporation state that the corporation was being formed for the
sole and specific purpose to engage in the [p]ractice of medicine. Exhibit E,
Summit P.C. Articles of Incorporation. Alex Pickens, Jr., MD, signed the Articles of
Incorporation as the sole incorporator.
33.

According to Summit P.C.s 2012, 2013, and 2014 Annual Reports filed

with LARA, the corporate purpose remained the practice of medicine. The 2012,
2013, and 2014 Annual Reports also show that Alex Pickens, Jr., MD was the
president, secretary, treasurer, director, and sole shareholder of Summit P.C.
Exhibit E.

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34.

However, Summit P.C.s 2015 Annual Report shows that Summit

P.C.s corporate purpose had changed and that Alex Pickens, Jr. MD was no longer
an officer, director, or owner of Summit P.C. Exhibit H. Instead, Summit P.C.s
purpose had changed to management company and David Lipton was listed as the
president, secretary, treasurer, director, and sole shareholder. Id.
35.

MCL 600.4501 commands the Attorney General to bring an action for

quo warranto where, as here, the facts clearly indicate that the action is warranted.
36.

Quo warranto is warranted since Summit P.C. is in violation of a

provision of the act or acts creating, offering, or renewing the corporation and has
violated the provision of a law under which the corporation forfeits its charter by
misuse. MCR 3.306(B)(1)(d) and (e).
37.

According to its articles of incorporation, Summit P.C.s corporate

purpose is the practice of medicine, which is an appropriate purpose for a

professional corporation. Yet Summit P.C.s 2015 annual report filed with LARA
now states that Summit P.C.s purpose is management company. Exhibit H. Such
an activity is not a professional service under MCL 450.1282(b) and is not a legal
activity for a professional corporation. MCL 450.1287(1) states: A professional
corporation shall not engage in any business other than providing the professional
service or services for which it was specifically incorporated.
38.

Additionally, Defendant David Lipton, who is listed on Summit P.C.s

2015 annual report as its sole officer, director, and shareholder, is not a licensed
person under the law. Therefore, Defendant Liptons role as sole shareholder of

13

Summit P.C. violates MCL 450.1283(2). Likewise, the transfer of ownership from
Alex Pickens, Jr., MD to Defendant Lipton violates MCL 450.1288(2).
39.

Dissolution under quo warranto is warranted here because Summit

P.C.s continued operation as a professional corporation violates Michigans laws for

professional corporations. MCL 600.4521 states:
If a corporation has, by any misuser, nonuser, or surrender, forfeited its
corporate rights, privileges and franchises, the judgment in an action for quo
warranto shall oust and exclude such corporation from such corporate rights,
privileges and franchises, and may dissolve the corporation. In addition
to such judgment or in lieu thereof (except in case of such surrender), the
court may impose a fine not exceeding $10,000.00 upon the
corporation. The fine will not prevent further prosecution for any
continuance or repetition of the conduct complained of. (Emphasis added.)
A fine is also warranted. Not only is Summit P.C. continually violating
Michigans laws of professional corporations, it is also doing so despite the Attorney
Generals recent investigation of Summit P.C. and Summit Inc. regarding this very
issue. That investigation found no apparent wrongdoing by those entities, yet not a
year after resolving that complaint, Summit P.C. and Defendant Lipton ignored
Michigans laws for professional corporations by altering Summit P.C.s corporate
purpose to a management company and transferring ownership to Defendant
Lipton, who is not a licensed physician. Moreover, by Summit P.C.s 2015 Annual
Report with LARA, Defendant Lipton falsely certified that he was licensed to
perform medical services. Exhibit H.
40.

In addition to the remedy of dissolution under quo warranto, Section

286 of the Business Corporation Acts chapter on professional corporations also

specifies that the appropriate remedy is dissolution. The failure of a professional
14

corporation to ensure that its shareholders are legally qualified to provided

professional services is grounds for the forfeiture of its articles of incorporation and
its dissolution, which may be brought by the Attorney General. MCL 450.1286.
41.

Injunctive relief, including a preliminary injunction, restraining

Summit P.C. from operating is also an appropriate remedy:

(1) Upon complaint being filed by the attorney general, the circuit court may
enjoin any corporation from assuming or exercising any franchise, liberty,
or privilege or transacting any business not authorized by the
corporation's charter. The court may in the same manner restrain any
individuals from exercising any corporate rights, privileges, or franchises
which have not been granted to them by the laws of this state.
(2) The court may issue the injunction before the answer, upon satisfactory
proof that the defendants have usurped, exercised or claimed any
franchise, privilege, liberty, or corporate right not granted to them; and
after the answer the injunction may be continued until final judgment is
had. [MCL 600.3601.]
42.

The Attorney Generals motion for a preliminary injunction will be

filed concurrently with the filing of this Complaint.

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COUNT II
DISSOLUTION OF SUMMIT P.C. BY ATTORNEY GENERAL
UNDER MCL 450.1821
43.

Plaintiff incorporates by reference the preceding paragraphs.

44.

Section 821 of the Business Corporations Act authorizes the Attorney

General to dissolve a corporation for any of the following acts:

(a) Procured its organization through fraud.
(b) Repeatedly and willfully exceeded the authority conferred upon it by
law.
(c) Repeatedly and willfully conducted its business in an unlawful
manner. [MCL 450.1821]
45.

Alex Pickens, Jr., MD incorporated Summit P.C. in May 2011 and was

listed as Summit P.C.s sole officer, director, and shareholder in its annual reports
with LARA through 2014.
46.

On October 2, 2013, Pickens signed four certificates of assumed names

for Summit P.C. that were filed with LARA in November 2013. Exhibit E.
47.

Yet on November 29, 2013, Pickenss bankruptcy petitionsigned by

Pickens under penalty of perjuryfailed to list Summit P.C. as an asset of

Pickenss. Exhibit G. This omission, combined with the terms of the Management
Agreement and other agreementswhich are favorable to Summit Inc.and the
2015 Summit P.C. corporate filing confirming Defendant Lipton as the sole
stakeholder of Summit P.C., suggests that Alex Pickens, Jr., MD was never the
owner of Summit P.C. and indicates that Summit P.C. may have procured its
organization through fraud and may have repeatedly and willfully exceeded its
authority. Discovery of these facts is necessary.
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COUNT III
QUO WARRANTO INJUNCTIVE RELIEF AGAINST SUMMIT INC.
AND DEFENDANTS LIPTON AND BURRELL
48.

MCL 600.3601 empowers this Court to enjoin any corporation from

assuming or exercising any franchise, liberty, or privilege or transacting any

business not authorized by the corporations charter. The court may similarly
enjoin any individuals from exercising any corporate rights, privileges, or
franchises which have not been granted to them by the laws of this state.
49.

Summit Inc. is a foreign corporation that has been operating in

Michigan since 2007 with a certificate authority to engage in management

services. Summit Inc.s Management Agreement with Summit P.C. details these
management services.
50.

As alleged above, Summit P.C. is operating in violation of its articles of

incorporation and the relevant chapter of the Business Corporations Act governing
professional corporations. Summit P.C.s Bylaws, Rules and Regulations of the
Professional Staff explains that Summit P.C.s Allied Health Professionals, which
include nurse anesthetists, nurse practitioners, physician assistants, and other
health professionals are subject to the supervision of a licensed physician. Exhibit
C, Paragraph 5.2.
51.

Because Summit P.C. lacks a shareholder who is a licensed medical

professional, Summit P.C. may not lawfully provide any medical services, nor may
it supervise any employees who may be performing these services. It follows that
Summit Inc. may not operate as a management company for a corporation that may
17

not legally operate in Michigan. Thus, this court should enjoin Summit Inc. and
Defendants Lipton and Burrell to ensure that neither it nor its employees or agents
are performing services for Summit P.C. and to ensure that Summit Inc. is not
performing any medical services. Additionally, a fine is warranted under MCL
600.4521.
PRAYER FOR RELIEF
Plaintiff Bill Schuette, Attorney General of the State of Michigan, prays that
this Court enter judgment in his favor and order relief as follows:
1.

Ordering Defendants to show cause why a preliminary injunction

should not issue (scheduling the show cause hearing within 14 days), and following
the show cause hearing:
a. preliminarily enjoining and restraining Defendants David Lipton,
Anise Burrell, and Summit P.C. and its employees and agents from
offering or providing medical services, practicing medicine, or
contracting to have medical services performed for Summit P.C.
b. preliminarily enjoining and restraining Defendant Summit Inc. and its
employees and agents from providing medical services, professional
services, or other services for Summit P.C.
c. preliminarily enjoining Defendants David Lipton and Anise Burrell
from incorporating, organizing, or doing business in the State of
Michigan as an owner, officer, or employee of any other corporation or
entity for the purpose of offering or providing medical services to the
18

public, practicing medicine, or contracting to have medical services

performed for such corporation or entity, unless and until they obtain
the requisite licenses and otherwise complies with Michigan law. [MCL
600.3601]
2.

Permanently enjoining Defendants Summit P.C. and Summit Inc. and

their employees and agents from offering or providing medical services to the
public, practicing medicine, or contracting to have medical services performed for
such corporations. MCL 600.3601.
3.

Permanently enjoining Defendants David Lipton and Anise Burrell

from incorporating, organizing, or doing business in the State of Michigan as an

owner, officer, or employee of any other corporation or entity for the purpose of
offering medical services to the public, practicing medicine, or contracting to have
medical services performed for such corporation or company, unless and until they
obtain the requisite licenses and otherwise comply with Michigan law. MCL
600.3601.
4.

Dissolving Defendant Summit P.C. and ousting and excluding such

corporation from such corporate rights, privileges and franchises. MCL 600.4521
and MCL 450.1286.
5.

Fine Defendants Summit P.C. and Summit Inc. up to $10,000 each for

misuse of their corporate rights, privileges, and franchises. MCL 600.4521.

6.

Order such other relief as is just and required by the circumstances.

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I declare that the statements above

are true to the best of my information,
knowledge, and belief:
_______________________________
Mark A. Gabrielse (P75163)
Assistant Attorney General
Subscribed and sworn to before me
this 7th day of April 2016.
_______________________________
Linda S. Miers
Notary Public, Jackson County, MI
(Acting in Ingham County)
My Commission Expires: 12/28/16
Respectfully submitted,
Bill Schuette
Mark A. Gabrielse (P75163)
William R. Bloomfield (P68515)
Assistant Attorneys General
Attorneys for Plaintiff
Corporate Oversight Division
P.O. Box 30755
Lansing, MI 48909
Telephone: (517) 373-1160

Dated: April 7, 2016

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